IR 05000483/1993008
| ML20045G281 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 07/02/1993 |
| From: | David Nelson, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20045G269 | List: |
| References | |
| 50-483-93-08, 50-483-93-8, NUDOCS 9307130129 | |
| Download: ML20045G281 (7) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-483/93008(DRSS)
Docket No. 50-483 License No. NPF-30.
Licensee: Union Electric Company Post Office Box 149 St. Louis, MO 63166 Facility Name:
Callaway Nuclear Power Station Inspection At:
Callaway Site, Callaway County, Missouri Inspection Conducted: June 7-8 and 10-11, 1993 Inspector:
/d bu 1 &A
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David M. Nelson ~~
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Radiation Specialist Approved By: Ib%BlAV N93 Will(Mnell, Chief Da'te "
l Radi6 logical Controls Section 2 Inspection Summary Inspection on June 7-8 and 10-11. 1993 (Report No. 50-483/93008(DRSS))
Areas Inspected:
Routine, announced inspection of the radioactive waste treatment, and effluent and environmental monitoring programs (Inspection Procedure (IP) 84750). The inspection also included tours of the' auxiliary and radioactive waste buildings and the spent fuel pool area. (IP 83750 and IP 86750).
Results: One violation was identified. All.three programs appeared to be effective in implementing the requirements of the regulations.
Excellent housekeeping practices were noted in the auxiliary and radioactive waste buildings.
Significant improvements in the control of contaminated materials were also noted:
a new in-process tagging system for contaminated materials had been developed and implemented and newly designed labels had been-developed and placed on all containers holding radioactive materials.
An area needing improvement was the licensee's quality control program for insuring that valid meteorological data is stored by the Radiological Release Information System (RRIS).
9307130129 930702 PDR ADOCK 05000403 O
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DETAILS q
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Persons Contacted
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- W. Campbell, Manager, Callaway Plant
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- C. Graham, Supervisor, Health Physics. Technical Services
- M. Evans,. Superintendent, Health Physics
- R. Miller, Supervisor, Radioactive Waste and Transportation
- J. Neudecker,' Supervisor, Health Physics Operations
- G. Randolph, Vice President, Nuclear Operations-
- B. Bartlett, Senior Resident Inspector j
The inspectors also interviewed other licensee personnel during' the-course of the inspection.
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- Denotes those present at the exit meeting on June 11, 1993.
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General This inspection was conducted to review aspects of the licensee's.
I radioactive waste treatment, and effluent and environmental monitoring
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programs. The inspection included tours of radiation controlled-areas, i
observations of licensee activities, review of representative records, i
and discussions with licensee personnel,
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3.
Organization. Manaaem:nt Controls, and Trainina (IP 84750)
The inspector reviewed the licensee's organization and management controls for the radioactive waste treatment, and effluent-and environmental monitoring programs, including:
organizational structure,
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staffing, delineation of authority, and training.
l The licensee's radioactive waste and transportation management
organization remains essentially as described in previous inspection
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reports and staffing within the group has remained very stable.
There have been personnel changes within the health physics (HP)
l technical support group. Two technicians had left the group; one was
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promoted and the other reassigned to the chemistry group. Management had changed as wel'; one manager was reassigned within the group and another left to join another outside organization.. Each vacated position had been filled from within and the individuals involved had
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received additional on-the-job and site specific training.
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No violations or deviations were identified.
4.
Access Control (IP 83750)
On January 6, 1993, the licensee's Suggestion Occurrence Solution system reported an incident in which one equipment operator (E0) violated
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i station procedures by entering rooms 1306A and 1306B to hang Workers i
Protection Assurance tags without the necessary health physics coverage required by the posting (" Radiation Area" and " Contact HP for Survey J
Prior to Entry") cutside the rooms.
The E0 was aware that he was required to have HP servey tne rooms before he entered.
Both rooms were locked.
Past surveys had indicated iat the radiological conditions in l
certain cubicles of both rooms could change rapidly and entry surveys in i
those areas were necessary. The E0 claimed that he had called HP for
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support and only after waiting for an unspecified period of time had he
entered the rooms. The operator also stated that he had read the survey.
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sheets before entering the RCA and had not entered the cubicles where the dose rates fluctuate. A review of the SOS and subsequent i
discussions with individuals involved indicated that even though HP had l
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been slow in responding to the E0's request for coverage and the E0 had been aware of the radiological conditions in.the areas of the rooms l
entered, the E0 had still violated a station procedure when he entered
the two rooms without an entry survey (procedure HDP-ZZ-01500
" Radiological Postings").
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Following the incident, the licensee took the following corrective actions.
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All HP operations personnel were required to read :he
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aforementianed S0S.
i Operations management met with the E0 and issued a verbal
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reprimand.
HP management met with the operations crews during their 1993 l
requalification cycle to discuss specific expectations for work in i
the RCA.
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Callaway Plant Policy 7.1 " Conduct of Work in the Radiological i
Controlled Area" was approved June 23, 1993, and includes the
following statement:
" Willful violations of posting instructions-l
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will not be tolerated and'will result in disciplinary action up to l
and including discharge."
Discussions with HP management indicated that the corrective actions taken appe7 red to be adequate. However, even though the incident had little safety significance and the corrective action taken appeared to
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have been adequate, the willingness of the E0 to violate station t
procedures precludes the use of exercising enforcement discretion
(IFI 50-483/93008-02).
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One violation was identified.
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Quality Assurance Surveillances (IP 83750 and IP 84750)
The inspector reviewed the extent, thoroughness, and results of several
surveillances performed since the last inspection.
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Quality assurance continues to conduct excellent surveillances, particularly in response to concerns or questions raised during previous inspections or by individuals and/or groups within the facility. The following are examples of surveillances conducted to address concerns raised in previous inspection eports:
SP93-002 " Review of the packaaino and transportation of
radioactive material prooram - 10 CFR 71. Subpart H." In a previous inspection report, questions were raised about the licensee's compliance with 10 CFR 71, Subpart H.
The auditors searched the relevant regulations and guidance documents and determined that the licensee had not adequately addressed the QA requirements under the subpart. As a result of the surveillance, the licensee decided to expand the number of audits of its vendors who supply their 10 CFR 71 packaging. This was an excellent surveillance.
SP93-001 " Controls on 10 CFR 61 Laboratory Vendors." Questions
were raised in a previous inspection report-about the licensee's.
responsibilities for auditing their Part 61 vendor laboratories.
As a result of the findings of the surveillance an audit was performed on their Part 61 vendor laboratory in April 1993.
This was an excellent surveillance.
SP92-104 " Pre-imolementation Surveillance of Operational Healt_h
Physics Procedures in Support of 10 CFR 20 New Rule Implementation." The licensee implemented the requirements of the
'ew 10 CFR 20 on January 1, 1993. The surveillance reviewed HP
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procedures to see if the licensee was in full compliance with the requirements of the new Part 20. The surveillance was good but rather limited in scope.
SE93-035 " Reduction of Reaulatory Burden." The surveillance
addressed, in part, concerns raised about the licensee's procedures for processing incoming packages containing radioactive materials. As a result of the surveillance's findings, the licensee revised the procedures for receiving radioactive material s. This was an excellent surveillance.
Other surveillances included the monitoring of a radioactive waste shipment and observations made during the testing of process and effluent monitors. Although limited in scope, both were effective in reporting full compliance with the licensee's procedures.
Several other surveillances conducted prior to the inspection had no been released: they will be reviewed during the next inspection.
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1993 audits of the radiation protection and the radioactive wane programs (which includes effluent and environmental monitoring) will also be reviewed during the next inspection.
No violations or deviations were identified.
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Chances in the Offsite Dose Calculation Manual (ODCM). Process Control
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Proaram (PCP). and Radwaste System Desian and Operation (IP 84750)
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i Since the last i..spection (50-483/92025(DRSS)), no changes have been
made in the ODCM, the PCP, or in the radioactive waste system processing
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design or operation. However, minor changes had been made to the
procedures governing the PCP to bring them into compliance with the new 10 CFR 20.
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A review of the 1992 Semiannual Radioactive Effluent Release Report indicated that the reports had been submitted as required, trends had i
been evaluated, and the format satisfied the requirements of Regulatory
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Guide 1.21.
i Since no changes were made to the design of the radioactive waste processing system or the PCP, none were noted in the semiannual Effluent
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Release Report.
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No violations or deviations were identified.
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Process and Effluent Radiat. ion Monitors (IP 83750_1
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The calibration and operability records of a number of process and effluent monitors were reviewed. The monitors included GTRT0021B (unit vent air monitor), HBRT0018 (radwaste building discharge line liquid
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monitor), BMRT0052 (steam generator blow /down discharge monitor), and
GHRT0010B (radioactive waste exhaust fans discharge monitor). The
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review indicated that each had been calibrated within the specified time
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requirements of the ODCM and the operability of the effluent monitors
during discharges had been excellent.
For example, the "18" monitor was
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operable during~ each of the more than 100 radioactive waste liquid
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eff%ent releases from the discharge monitor tanks during 1993.
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i A review of the surveillance incking system database records also j
indicated that the functional tests (instrument surveillance functional l
(ISF) tests) as specified in the ODCM had also been performed on the
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same four instruments in a timely manner.
A further review of the
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records indicated that each instrument's alarm / trip setpoints had been i
properly set according to ODCM guidelines.
No violations or deviations were identified.
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8.
Radioactive Waste Storaae (IP 84750)
Beginning June 1,1994, the licensee plans to store spent resins and l
mixed waste in an open area adjacent to the radioactive waste building.
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Discussions with radioactive waste management indicated that the 10 CFR 50.59 safety evaluations for both had not been completed. The i
licensee had been shipping all of its waste to the Barnwell,.
i South Carolina, waste site and had only been storing mixed waste and a
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number of ex-core detectors on site in the radioactive waste building.
During the inspection, radioactive waste personnel were observed
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preparing and processing the ex-core detectors for shipment to Barnwell.
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and the licensee anticipates that most of the mixed waste (contaminated oils) will eventually be burned by the licensee on site and the rest will be stored on site for eventual disposal.
No violations or deviations were identified.
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Meteorolocical Monitorina Program (IP 84750)
A review of the records for the meteorological (met) tower instruments
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(10 and 60 meter wind speed and wind direction, 60-10 meter temperature difference, precipitation and 90 meter dew point) indicated that the F
instruments were fully operational approximately 95% of the time (ranging from 99.98% for the 10 meter wind speed to 91.76% for the 90 meter dew point). The data indicates that the meteorological measurement program is effectively implemented.
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A few weeks before the inspection, however, HP technical services discovered that actual meteorological data from the met iower had not
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been stored in the radiological release information system (RRIS).
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Meteorological data can be downloaded into the RRIS database either automatically (actual data from the met tower) or manuall.r (operator
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data).
If an operator sets the switch to manual mode, on' y those parameters set by the operator are downloaded into the dnabase. The
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licensee has used the manual mode for training purposes since about 1990
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and HP technical services had recently discovered that on numerous l
occasions the operators had failed to reset the switch to automatic mode l'
following a training session. This means that for these occurrences, invalid meteorological data would have been stored in the RRIS.
Preliminary evaluations of the data indicate that in 1991 and 1992, as much as 15% of it was manually set. Since this data is used to generate
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the semi-annual effluent release reports, the doses reported to the NRC -
in the 1991 and 1992 reports are probably inaccurate.
During the J
inspection, the decision to bring in a professional meteorologist to review the data was approved by management.
Pending a review of the meteorologist's analyses, this is an unresolved item (50-483/93008-01).
No violations or deviations were identified.
One unresolved item was j
identified.
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Effluent Releases (IP 84750)
A review of the effluent summaries indicated that since January 1,1993, the licensee had made approximately 100 liquid and four airborne batch rel eases.
The airborne release sammary indicated that 2.3E+02 (8.51E+03), 1.15E-04 (4.26E-03), 1.05E-03 (3.9E-02), and 3.lE+01 (1.15E+03) curies (MBq) of respectively noble gases, iodines, particulates, and tritium was released.
For liquids, 6.72E+02 (2.5E+04)
and 1.53E-03- (5.7E-2) curies (MBq) of respectively tritium, iodines, and particulates were released in a total volume of 3.56E+10 milliliters.
These values indicate that for the first half of 1993 the effluent i
releases were well within the regulstory limits.
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No violations or deviations were identified.
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Plant Tours (IP 83750)
i The inspector toured the auxiliary and radwaste buildings and found that
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although there were minor incidences of debris on the floor in the radioactive waste buildings, housekeeping practices in both buildings were excellent. Radiological controls (postings, barriers, etc.) in both buildings were appropriate and within the regulatory requirements.
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In a response to concerns raised in inspection report 50-483/92025(DRSS), the licensee had taken steps to identify and label all of the containers (drums and metal boxes) holding radioactive materials.
No examples of mislabeled or unlabeled containers were
found.
The licensee also improved its methodology for identifying i
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radioactive materials in the radiological controlled areas. All materials were tagged with an in-process card identifying the material and who was responsible for its disposition. The reduction in the
amount of contaminated material stored in the auxiliary building
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indicated that the new tagging system was working.
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No violations or deviations were identified.
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12.
Exit Interview (IPs 83750. 84750. 86750)
The inspector met with licensee representatives (denoted in Section 1)
at the conclusion of the inspection on June 11, 1993, to discuss the i
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scope and findings of the inspection.
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During the exit interview, the inspector discussed the likely informational content of the inspection report with regard to documents
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or processes reviewed by the inspectors during the inspection.
Licensee representatives did not identify any such documents or processes as proprietary. The following matters were specifically discussed, a.
Excellent housekeeping practices in the auxiliary and radioactive waste buildings.
(Section 11)
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Inaccurate meteorologi'al data.
(Section 9)
c.
10 CFR 50.50 safety evaluations for the storage of low-level and I
mixed waste.
(Section 8)
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The violation of station procedure and the potential violation of
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NRC regulations involving the entry of a egalpment operator into rooms 1306 A and B without a prior survey.
(Section 4)
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